Privacy Policy

Our Commitment to Your Privacy
Information LighterLife gathers and tracks
Children
How We Use the Information
How long is the Information kept for?
How is the Information Protected?
Your Rights
LighterLife Applications
Legal
Extent of Terms
How to contact us

Our Commitment to Your Privacy

(effective from 12 April 2018)

View archived version

We are LighterLife UK Limited (Registered No: 3164308, VAT Registration No: 666003451) whose registered address is at Cavendish House, Parkway, Harlow Business Park, Harlow, Essex CM19 5QF.

All references in this privacy policy to 'we/our/us' refer to LighterLife UK Limited and its affiliate companies which are in the same group of companies as LighterLife UK Limited.

Definitions:

"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it;

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data;

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

"Data controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

"Data Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

“Application” means the hardware or software by which the Personal Data of the User is collected.  This includes the LighterLife website, members area, and the LighterLife game and App;

“User” means you, the individual using an Application;

This website at www.lighterlife.com and the Application is owned and operated by LighterLife. Your privacy when you use our website and/or Application is of the utmost importance to us. At LighterLife, we want to make your experience online satisfying and safe.

Because we gather certain types of information about our users, we feel you should fully understand our policy and the terms and conditions surrounding the capture and use of that information. This privacy statement discloses what information we gather and how we use it.

Please read this privacy policy carefully before submitting any of your personal information to us.

This privacy policy may be updated from time to time. The date of the most recent revisions will appear on this page so please visit this privacy policy each time before you submit your personal information.

Information LighterLife gathers and tracks

LighterLife collects and processes a range of personal data relating to individual prospective customers, customers, individuals seeking a Franchisee opportunity, Franchisees, and Application users.

LighterLife may collect this information in a variety of ways.  For example, data might be collected when accessing or signing up to any of the LighterLife’s services, activities, online content, or when visiting one of our trained LighterLife Counsellors or Mentors.

The general categories of personal data that we may collect and process about you are:

  1. Profile data which may include name, gender, height, or Date of Birth;
  2. Contact data which may include email address, postal address, telephone or mobile number;
  3. Health data in the form of Wellness Profiles and Wellness Updates;
  4. Plan data on the LighterLife plans you’ve participated in e.g. weekly weigh-ins and ketosis markers, Counselling activities, and photographs;
  5. Account data which may include orders, baskets, delivery and billing addresses, payments, product reviews, and subscriptions;
  6. Application data which may include registration, authentication, weights, game points, App achievements, goals, or open letters;
  7. Usage data which is information collected automatically from Applications (or third party services employed by LighterLife), which can include: the IP addresses or domain names of the computers utilised by the Users who use LighterLife Applications, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (e.g. successful outcome, error), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment;
  8. Correspondence data in the form of email, telephone conversation notes, Live chat, surveying, complaints, and letters;
  9. Telephone data which may include inbound call details, dialled numbers, and recordings;
  10. Competition data which may include competition entrants and winners via the LighterLife Website, Social Media platforms, and Magazines;
  11. Activity data. This data allows an Application to use the activity data collected by your device in order for the Application to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.  Depending on what is described below, third parties may be involved in the activity tracking. Most devices allow for the User to control which Data is accessed or stored.

Apple HealthKit (Apple Inc.): HealthKit is an activity data handling service provided by Apple Inc. that enables the Application to access or store activity data.  The personal data collected is movement activity.

  1. Public Relations data which may include stories and images of LighterLife clients and Journalist details;
  2. Franchise data involved in the recruitment and management of LighterLife Franchises. This may include information on the business, background checks, license, performance, premises, training, or banking;

In addition to the information contained in this privacy policy, an Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

Children

Our Applications and services are not designed for, or directed to, individuals under the age of 16.

We will never knowingly request personal information from anyone under the age of 18 without requesting parental consent.

How We Use the Information

LighterLife uses your personal information to maintain and manage your account, deliver services that you have requested, and generally enhance your experience. Examples include, but are not limited to:

  • Providing our services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
  • Applying safeguards to ensure that the right LighterLife plan is being offered to you;
  • Keeping track of your LighterLife journey;
  • Processing your orders for products and participation in groups to be provided to you;
  • Locating and putting you in touch with a Mentor or Counsellor in your area;
  • Providing you with Mentoring support when you’re on your LighterLife journey;
  • Providing you with the most user-friendly online navigation experience;
  • Processing and tracking your membership and magazine subscriptions;
  • Managing LighterLife competitions;
  • Processing your request to become a LighterLife Franchisee;
  • Providing the services you request;
  • Processing and tracking your purchases of LighterLife products and services to a LighterLife Friend who refers you to LighterLife;
  • Sending you other administrative and marketing communications;
  • Sending you surveys;
  • Provide personalised services where we analyse the information you supply, as well as your activity on our (and other) services, so that we can offer a more relevant, tailored service;
  • Utilising prospecting and retargeting services provided by the likes of Google and Facebook;
  • Listening to telephone recordings in response to queries, or for training and development purposes;
  • Providing you with information which may be of interest to you from time to time (where you consent to receiving this);
  • We may use IP addresses and device identifiers to identify the location of users, to block disruptive use, to establish the number of visits from different countries, and to determine whether you are accessing the services from the UK or not. If you are accessing services from outside the UK, you may be re-directed to the international version of the LighterLife website;
  • We may use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes;

We use tracking information to determine which areas of our sites users like and don't like based on traffic to those areas. We do not track what individual users read, but rather how well each page performs overall. This helps us continue to build a better service for you. We track search terms entered in search functions as one of many measures of what interests our users. But we don't track which terms a particular user enters.

Contacting you for marketing purposes

LighterLife will only send you marketing emails or contact you where you have consented to this.

We offer regular emails, to let you know about exclusive offers, competitions, tips and weight-loss support, and other exciting LighterLife information ranging from celebrity news to business opportunities.

We may personalise the message content based upon any information you have provided to us and your use of LighterLife Applications.

You can “opt out” of marketing communications at any time, by emailing us at privacy@lighterlife.com inserting “UNSUBSCRIBE” as the subject or clicking on the “UNSUBSCRIBE” link found at the bottom of marketing emails.

Sharing your personal information with third parties

LighterLife contracts with other companies to obtain certain services on our behalf, including order fulfilment, credit card processing, delivery, and marketing. We provide these companies only with the information they need to perform their services, and they are permitted to use the information only for that specific purpose or as required by law, or if you have agreed to any additional use or sharing of your information.

LighterLife will share your personal information with your local Mentor or Counsellor from time to time to enable them to contact you for the following purposes:

  • Provide you with support and counselling services
  • Conduct market research and surveys on behalf of Lighterlife (if you have chosen to participate)
  • To send you information which may be of interest to you (if you have consented to receive this)

LighterLife will share your personal information with Friends who are licensed by LighterLife to refer customers to LighterLife and who have referred you to us, or where you have quoted their unique tracking code when you have purchased a product and/or service from us. The information we may share with them will be limited to your name, e-mail address, and the volume/value of Foodpacks and/or groups sessions you have purchased from either a Counsellor or Mentor, or from LighterLife2U.

International Data Transfers

Occasionally, LighterLife may transfer Personal data outside the EEA to an ‘International Recipient’ e.g. where LighterLife elects to use the Cloud for storing data, the hosting service provider with off-shore data centres will be chosen on the basis that they can demonstrate their data practices comply with the requirements of applicable Data Protection Laws.

Where personal data is transferred outside the EEA, all transfers by LighterLife to an International Recipient shall (to the extent required under Data Protection Laws) be affected by way of Appropriate Safeguards (e.g. Privacy Shield, declaration of adequacy) and in accordance with the applicable Data Protection Laws.

How long is the Information kept for?

We will only keep information about you for as long as we need to. We make sure that any companies which process your data on our behalf do the same. We have an internal retention policy where there are varying retention periods for the different categories of information depending on our legal obligations and whether there is a commercial need, such as answering customer account queries.

When your personal information is deleted the remaining information is anonymised for analytical purposes.

How is the Information Protected?

LighterLife takes the security of personal data seriously. LighterLife has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed without our authorisation.

Where LighterLife engages third parties to process personal data on its behalf, such parties do so under contract and on the basis of our written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

All personally identifiable information is subject to restricted access to prevent unauthorised access, modification or misuse. Please note, however, that we may release your personal data if required to do so by law, or by search warrant, subpoena or court order.

Your Rights

As a data subject, you have a number of rights in relation to your personal data.

Subject access requests

You have the right to make a subject access request. If you make a subject access request, we will tell you:

  • whether or not your data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected directly from you;
  • to whom your data may be disclosed to, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
  • for how long your personal data is stored (or how that period is decided);
  • your rights to rectification or erasure of data, or to restrict or object to processing;
  • your right to complain to the Information Commissioner if you think LighterLife has failed to comply with your data protection rights; and
  • whether or not LighterLife carries out automated decision-making and the logic involved in any such decision-making.

We will also provide you with a copy of the personal data undergoing processing. This will normally be in electronic form if you’ve made a request electronically, unless you agree otherwise.

If the you want additional copies, we will charge a fee, which will be based on the administrative cost in providing the additional copies.

We normally respond to a request within a period of one month from the date it is received. In some cases, such as where LighterLife processes large amounts of your data, it may respond within three months of the date the request is received. We will write to you within one month of receiving the original request to you if this is the case.

If a subject access request is manifestly unfounded or excessive, LighterLife is not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which LighterLife has already responded. If you submit a request that is unfounded or excessive, we will notify you that this is the case.

To obtain a copy of the personal data we hold about you, please write to us at the following address: Privacy Co-ordinator, LighterLife, Cavendish House, Parkway, Harlow Business Park, Harlow, Essex CM19 5QF enclosing your postal details, and proof of ID (a copy of your driving license or passport, and such copy being signed and dated by you).

Other rights

You also have a number of other rights in relation to your personal data. You can request LighterLife to:

  • rectify inaccurate data;
  • stop processing or erase data that is no longer necessary for the purposes of processing;
  • stop processing or erase data if your interests override LighterLife's legitimate grounds for processing data (where LighterLife relies on its legitimate interests as a reason for processing data);
  • stop processing or erase data if processing is unlawful; and
  • stop processing data for a period if data is inaccurate or if there is a dispute about whether or not your interests override LighterLife's legitimate grounds for processing data;

To ask LighterLife to take any of these steps, you should send the request to privacy@lighterlife.com.  In some cases, we may need to ask for proof of identification before the request can be processed. We will inform you if we need to verify your identity and the documents you require to support this.

LighterLife Applications

There are many features available through LighterLife Applications where no registration is required. However, if you are interested in obtaining information, products or services from LighterLife, or in participating in certain activities through LighterLife Applications (such as locating a Mentor in your area, purchasing LighterLife product in the LighterLife shop, subscribing to our high quality magazine, expressing your interest in becoming a self-employed LighterLife Mentor, or being supported by the LighterLife App), you may need to provide us with this information about yourself. For example, to purchase from the LighterLife shop we need to collect information about you to process the transaction, fulfil your order and provide you with the services and communications you expect.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.

The Personal Data may be freely provided by the User or collected automatically when using an Application.

Any use of Cookies - or of other tracking tools - by an Application or by the owners of third party services used by an Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Failure to provide certain Personal Data may make it impossible for an Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through an Application and confirm that they have the third party's consent to provide the Data to the Owner.

LighterLife also collects Non-Personal Information.  This is information LighterLife gathers through aggregated tracking information derived mainly by tallying page views throughout our sites. This information allows us to better tailor our content to readers' needs and to help our advertisers and sponsors better understand the demographics of our audience.

Apps and Devices

When you download or use LighterLife apps on your mobile device, information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie, such as by enabling the app to ‘remember’ you or provide you with the content you have requested.

Your web browser or device may also provide LighterLife with information about your device, such as a device identifier or IP address. Device identifiers may be collected automatically, such as the device ID, IP address, MAC address, IMEI number and app ID (a unique identifier relating to the particular copy of the app you are running).

When you sign in to a LighterLife app, your sign-in details may be stored securely on the device you are using, so you can access other LighterLife apps on the same device without needing to enter your sign-in details again.

Registration and authentication

By registering or authenticating, Users allow Applications to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. When this is the case, the Application may be able to access some data, stored by these third party services, for registration or identification purposes.

Facebook

LighterLife Applications may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it.  For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

Actions with Facebook include:

  • Facebook Authentication (Facebook, Inc.): Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
  • Access to ‘basic information’: by default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
  • Access to ‘About Me’: provides access to the 'About Me' section of the profile.
  • Access to ‘contact email’: access the User's contact email address.
  • Access to the Facebook account: This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
  • Facebook Like button and social widgets (Facebook, Inc.): The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Access to third party services' accounts

This type of services allows Applications to access Data from your account on a third party service and perform actions with it.

These services are not activated automatically but require explicit authorisation by the User.

Linking to other websites

Our Applications may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of personal information you submit whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

Interaction with external social networks and platforms

This type of services allows interaction with social networks or other external platforms directly from LighterLife Applications.  The interaction and information obtained through the Application are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

System logs and maintenance

For operation and maintenance purposes, an Application and any third party services may collect files that record interaction with an Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Usage tracking

LighterLife tracks user traffic patterns throughout all our sites. However, we do not correlate this information with data about individual users. LighterLife does break down overall usage statistics according to a user's domain name, browser type, and MIME type (i.e. identifying files on the internet according to their nature and format) by reading this information from the browser string (information contained in every user's browser).

Cookies

We use cookies to give you the best browsing experience and to help us understand how you use our site. Cookies are small snippets of data stored on your computer and some have already been set. By continuing to use our website you are accepting our use of cookies.

What are cookies?

Cookies are files that contain small amounts of data. They are placed on your computer or other device by the websites you visit.

Different kinds of cookies do different things ranging from making a website work to making it easier to use and enabling website owners to understand more about their visitors.

We use cookies to:

  • Ensure your privacy is safeguarded in any secure area
  • Gather information about which pages are most relevant to visitors
  • Store details you enter into our calculators, tools and demos so you can make the most of our online services
  • Store details of your marketing, product and other preferences to enhance your visits
  • Evaluate how effective our advertising and promotions have been to improve our performance

We don’t use cookies to:

  • Store information which means that you can be personally identified
  • Track your browsing after you've left our websites
  • Sell or distribute cookie data (without your consent)

What happens if I turn off cookies in my browser?

Up-to-date browsers give you the option to accept or decline cookies. This is a global setting that applies to every website you visit.

If you do switch off cookies at a browser level, your device won't be able to accept cookies from any website. This means you will struggle to access the secure area of any website you use, and you won't enjoy the best browsing experience when you are online.

If you want to change the cookies settings in the browser you're currently using, please go to:

the online help section for your browser settings > under the bonnet > content settings > cookies settings > internet options > privacy > advanced (this will depend on your browser)

Legal

This website (excluding linked sites) is controlled by LighterLife UK Ltd which is a company established in the United Kingdom. The site can be accessed from various other countries around the world. This privacy policy is governed by English law. You also agree and hereby submit to the exclusive jurisdiction of the courts of the United Kingdom with respect to such matters.

The User's Personal Data may be used for legal purposes by LighterLife as the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request by public authorities.

Extent of Terms

The services available on this website and use of LighterLife Applications are only for persons resident in the United Kingdom and the Republic of Ireland. Information regarding products, services, rates and promotions are applicable to these countries only.

No representation or warranty is given that the materials contained in the site or the Application are appropriate to, available in or relevant for any other location.

How to contact us

If you any questions or comments about this Privacy Policy, please contact us at:

Privacy Co-ordinator

LighterLife,

Cavendish House,

Parkway, Harlow Business Park,

Harlow, Essex CM19 5QF

Or

Email: privacy@lighterlife.com